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Announcing the publication of its 2012 annual letters, which set out the complaints record of all universities under the OIA scheme, Rob Behrens, chief executive of the watchdog, said not all institutions were following the organisation’s guidance on when to declare student complaints.

Currently, universities are required to report complaints once a student has exhausted the institution’s internal appeals procedure and a student’s complaint has not been upheld.

Once this has happened, a Completion of Procedures letter should be automatically issued – a move which informs students that they can take their grievance to the OIA for independent consideration.

However, some universities are only issuing CoP letters if a student requests them, while others have lengthy, multi-stage processes which deter many students from pursuing their complaint to the end, Times Higher Education revealed last month.

“There is still work to do to make sure that all universities follow OIA guidance on Completion of Procedures letters,” said Mr Behrens said.

Universities also need to “[understand] the reasons why cases that turn out to be justified or partly justified have not been resolved at the university”, he said.

The annual letters are published to “increase public scrutiny of complaints handling records in universities” and “increase complainant confidence in university complaints handling processes”, the OIA says.

However, it is unwise to compare the number of CoPs at different institutions because different universities have different processes in managing and closing complaints, the OIA warns.

“It is not always possible to assume that the number of ‘Completion of Procedures’ letters accurately reflects the number of complaints and appeals which have been through formal university processes,” the OIA said.

However, Mr Behrens said the information from the annual letters provides a “sector overview” which is “extremely helpful”, despite the difficulty in comparing institutions.

“The annual letters help to identify patterns, but it is important not to make comparisons that are not supported by the data,” said Mr Behrens.